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November 8, 2023

Washington Dispatch for October 2023

The latest edition of Ernst & Young's Washington Dispatch is attached below. Prepared by Ernst & Young's International Tax and Transaction Services group, this monthly newsletter summarizes recent developments in US international taxation. Highlights of this month's edition include:

Top story

  • OECD releases text of Amount A Pillar One MLC, Treasury announces consultation

US Congress

  • House of representatives elects new Speaker
  • US-Taiwan legislation moves forward

IRS news

  • IRS proposed regulations would amend Section 367(b) regulations applying to certain cross-border triangular reorgs, inbound nonrecognition transactions
  • US officials offer update on pending guidance
  • IRS informing taxpayers of Schedule UTP non-compliance
  • IRS sending compliance alerts to US subs of foreign-owned corporations
  • IRS to broaden scope of corporate PLRs

Tax treaties

  • US-Chile tax treaty’s US reservations reflect current policy

Transfer pricing

  • IRS appeals Tax Court’s latest decision in Medtronic
  • US, Israel sign CAA on exchange of CbC reports
  • Cyprus issues clarification note on future CbC exchange agreement with US

OECD developments

  • OECD/G20 Inclusive Framework launches Multilateral Convention to implement Pillar Two Subject to Tax Rule
  • BEPS IF considering Pillar Two guidance on deferred tax assets
  • OECD FTA agrees on action to support continued digital transformation, delivering Pillar Two and capacity building
  • OECD releases outcomes of sixth peer review on BEPS Action 13 on CbCR


Washington Dispatch for October 2023